"The district court’s decision below characterizes the claim at an impermissibly high level of generality . . . the district court disregarded the claimed advance over the prior art of an improved digital picture frame with a physically separable user interface . . . The district court’s quote of the claim language leaves out the critical claim limitation that the user interface “is physically separable from said at least one digital picture frame” . . . the district court’s erroneous characterization of the claim all but ensured the incorrect conclusion that the claim was not directed to a technological improvement but instead impermissibly claimed only a result. In sum, we conclude that claim 19 of the ’573 patent is not directed to an abstract idea under Alice step one and is therefore patent eligible under § 101."

"Given that the ’104 patent issued over Shenzhen’s ’982 patent, its issuance would suggest there is some patentable difference between each patent’s claimed design, and, by extension, the ’982 patent and defendants’ accused products . . . The district court concluded this undermined Shenzhen’s likelihood of success on its infringement claim, making preliminary injunctive relief inappropriate."

"Shenzhen argues that the district court violated the doctrine of collateral estoppel by allowing the New Defendants to advance arguments regarding the ’104 patent’s issuance that the district court had previously rejected . . . The suggestion that the district court’s denial of reconsideration had collateral estoppel effects that barred the court’s reconsideration of its rationale, or the arguments the district court previously considered, lacks merit . . . “There is no basis for using res judicata or collateral estoppel to prevent a judge from reconsidering an earlier ruling in the same, ongoing case.”"

"Shenzhen is correct that the test for obviousness differs from the test for infringement . . . However, any suggestion that the district court held otherwise is unsupported by the record . . . Rather, the district court noted that the test for anticipation mirrors the test for infringement of design patents . . . we understand the district court to have assessed the strength of Shenzhen’s infringement claim via an analysis rooted in this court’s caselaw holding that anticipation and infringement are the same inquiry for design patents . . . when a design patent issues over an earlier one, the presumption of patent validity suggests that the later claimed design is not anticipated by—i.e., not substantially the same as—the earlier patented design."

"substantially preventing movement of the running belt in a second direction opposite the first direction." (emphasis added)

"[W]e conclude that the district court overlooked intrinsic evidence when it rejected Woodway’s suggested plain and ordinary meaning of “substantially prevent” . . . The district court concluded that the Asserted Patents “do not elaborate on the degree to which the safety device impedes rotation of the belt in the second direction.” This, however, is untrue: the claim language broadly specifies that rotation in the second, dispreferred direction is “substantially” prevented. As Woodway points out, “[t]he word ‘substantially’ is commonly used in patent claims and readily understood as a term of approximation meaning, for example, ‘largely but not wholly’” . . . when such safety devices are mentioned, nothing indicates that the prevention of dispreferred rotation must be total: instead, language like “help prevent undesirable forward rotation” appears alongside language like “permit rotation . . . in only one direction” and “prevent[ ] . . . forward rotation” . . . Such phrases either explicitly indicate that the prevention is not expected to be complete or do not specify the extent to which rotation is prevented in the dispreferred direction . . . Under these circumstances, we decline to find “words or expressions of manifest exclusion or restriction” in the Asserted Patents’ specifications that limit the plain and ordinary meaning of the “substantially prevent[ ]” limitation."

"[W]e do not believe that either subsequent amendment or arguments based on this rejection effected a clear and unmistakable disclaimer of claim scope . . . Woodway amended the above claim language to instead specify that the safety device “substantially prevents rotation of the portion of the safety device, the running belt and . . . at least one of the front shaft and the rear shaft”. . . In context, this amendment does not, as the district court concluded, “clarify that the running belt does not move in two directions” . . . Rather, through this amendment, Woodway called attention to a broader difference between its claimed invention and Bostic: . . . as Woodway argues, saying that Bostic’s belt is “free to move” in both directions says nothing about the amount of limitation the claimed treadmill places on the dispreferred direction of movement—it simply distinguishes a device that impedes movement in one direction from a device that does not . . . We therefore find no prosecution history disclaimer resulting from Woodway’s arguments on Bostic."

"In February 2014, 4DD became aware the government had exceeded the terms of its license and notified SMS. In August 2014, 4DD directly contacted the government to discuss the excess copies and requested payment for what it estimated to be 68 additional Federator cores . . . The trial court rejected 4DD’s argument that the evidence proved an established royalty rate and instead used a hypothetical negotiation to fix a reasonable royalty. After establishing the hypothetical negotiation date as August 27, 2013, the trial court considered the relevant Georgia-Pacific factors and found that the government would have possessed the superior bargaining position in this hypothetical negotiation . . . It determined that 4DD’s bargaining position was weakened given that (1) TETRA provided the government with little value, (2) TETRA had no established profitability, and (3) there existed a similar and cheaper software, Rhapsody . . . 4DD contends, the trial court committed legal error when it estimated royalty rates for the TETRA software using a hypothetical negotiation framework rather than simply adopting the established and previously agreed upon License or SEWP rates . . . Neither statute nor case law requires automatic adoption of royalty rates set out in licensing agreements when calculating infringement damages . . . Thus, the relevance of licensing agreements varies with the degree to which those agreements parallel the infringing activity . . . while a license may inform the reasonable royalty inquiry, no rule of law compels courts to defer to such an agreement in lieu of conducting a hypothetical negotiation, particularly where material differences exist between the terms of the license and the defendant’s infringement." (emphasis added)

"4DD contends that the trial court adopted an overexpansive view of the book of wisdom. . That is, the trial court constructed the hypothetical negotiation with the knowledge that the government would later cancel its work with TETRA before it could be successfully implemented. 4DD suggests this amounts to legal error . . . this so-called book of wisdom allows courts to consider later-occurring events when appraising the value of a patent or copyright at an earlier point in time"

"Here is a book of wisdom that courts may not neglect. We find no rule of law that sets a clasp upon its pages, and forbids us to look within."

"The purpose of the book of wisdom is to provide insight and reduce uncertainty as to the elements of a license the parties are hypothetically negotiating . . . It may not, therefore, be used to impute knowledge of later-occurring events affecting the value of the license that were unforeseeable at the time of negotiating, such as the government’s change in leadership and resulting decision to end its work with TETRA before implementation . . . Because we cannot separate the court’s error in applying the book of wisdom from its assessment of the parties’ respective bargaining positions, which has implications for the outcome of the hypothetical negotiation, we must vacate and remand for further proceedings." (emphasis added)

"We conclude . . . that the KNL defendants have, at a minimum, shown that there is a substantial question regarding whether the accused door can satisfy a claim limitation requiring a panel that is “flexible along [its] entire length” . . . We see nothing in the specification or prosecution history suggesting that the claim language does not mean what it says when it requires a “second outermost surface” which is “form[ed]” from “foam insulating material . . . during prosecution Cold Chain . . . stated that “[t]he sandwich structures of Rauenbusch are not the same as [the] claimed structure” because “the Rauenbusch sandwich structures do not include a foam insulating material forming the second outermost surface of the door.” We likewise conclude that there is a substantial question regarding whether the accused door is an “insulated overhead door” . . . as that term is used in claim 1."

"[W]hile Ridge alleged that it had been forced to sell its doors at reduced prices because of the alleged infringement by the KNL defendants, it failed to show that there was any causal nexus between sales of the accused doors and the prices Ridge set for its own doors . . . . We conclude, moreover, that the district court erred in determining that injunctive relief was merited based upon the Ridge plaintiffs’ assertions that: (1) TTPS incorrectly stated that the accused door was patented when it instead was the subject of a pending patent application; and (2) Kirk interfered with Ridge’s business relationships by sending a letter to Whiting Door threatening royalty damages."